RCRA Public Participation Manual - Tools
EPA-530-F-20-001 | https://www.epa.gov/rcra
Fact Sheets/Statements of Basis
The fact sheet/statement of basis is a brief document written in plain English to help residents understand highly
technical laws, concepts, and information. The purpose of fact sheets/statements of basis is to provide site-related
information to affected communities.
Required Activity?
Yes. Fact sheets, or statements of basis (when a fact sheet is not prepared), are required to be prepared by the
permitting agency when the draft permit or notice of intent to deny permit is issued for major hazardous waste facilities
or facilities raising significant public interest (40 CFR  , .24. ).
More detailed information on fact sheets, statements of basis, and other public participation activities for use at various
stages of the RCRA process can be found in Chapter 5 of the 2016 Edition of the RCRA Public Participation Manual.
Making it Work
When to Use
While fact sheets/statement of basis are required for draft permits, they can also be very helpful at other times
throughout the permitting process by providing a summary of the status of a draft permit application. The fact sheet/
statement of basis must be sent to the permit applicant as well as any other persons who request it (see 40 CFR 124.8
for more detailed information what should be included in a fact sheet or statement of basis). The same concept also
applies with respect to corrective action or enforcement processes.
How to Use
The first step in preparing a fact sheet or statement of basis is to determine the information to be presented. EPA
decision-making regulations require that RCRA permit fact sheets contain the following types of information:
	A brief description of the type of facility or activity which is the subject of the draft permit;
	The type and quantity of wastes covered by the permit;
	A brief summary of the basis for the draft permit conditions and the reasons why any variances or alternatives to the
proposed standards do or do not appear justified;
	A description of the procedures for reaching a final decision, including the beginning and ending dates of the public
comment period and the address where comments can be sent;
	Procedures for requesting a public hearing; and
	Name and telephone number of a person to contact for additional information.
A statement of basis is prepared the same way as a fact sheet. The statement of basis summarizes essential information
from the RCRA Facility Investigation (RFI) and Corrective Measures Study (CMS) reports and the administrative record.
The RFI and CMS reports should be referenced in the statement of basis. The statement of basis should:
Briefly summarize the environmental conditions at the facility as determined during the RFI
Identify the proposed remedy.

RCRA Public Participation Manual - Tools
Fact Sheets/Statements of Basis

-------
SEPA	RCRA Public Participation Manual - Tools
https://www.epa.gov/rcra
	Describe the remedial alternative evaluated in sufficient detail to provide a reasonable explanation of each remedy.
	Provide a brief analysis that supports the proposed remedy, discussed in terms of the evaluation criteria.
Select a simple format for presenting the information. Avoid using bureaucratic jargon, acronyms, or technical language
in the text and be concise. Keep the following suggestions in mind as you format your fact sheet or statement of basis:
Message: Before writing, identify your message. Most people cannot retain more than three primary messages from a
document. Superfund focus groups show that several single-page fact sheets spread out over time are more effective
than one long multi-page fact sheet.
FYI content: Also include special information, such as dates of upcoming meetings, location and hours of the Information
Repository, and contact names, addresses, local and toll-free phone numbers, fax numbers, and E-mail addresses. Always
put special information in a text box in the lower right corner. Include the fact sheet date and number.
Format: The format should be easy to read. Make fact sheets visually interesting by using pictures, graphs, or diagrams to
accompany textual information. Too much text and not enough white space makes the page appear gray and daunting.
Place pertinent facts in text boxes, or make them stand out some other way.
Presentation: Make the permitting agency and the site name prominent in the banner. Always start with the primary
message in the upper left corner. Put it in a box or in some other eye-catching format. Use a catchy (not hokey) headline.
Vary the color of new fact sheets. When designing the layout, ensure the colors and graphics will also be clear when
printed/copied in black and white.
Writing: Generally, material prepared for the general public should be written at the eighth-grade level. However, check
site demographics and write at the grade level indicated. (LandView demographic profiles are available in every region
and over the Internet.) Use Grammatik (available in WordPerfect) to check for readability. Avoid bureaucratic jargon or
highly technical language. If necessary, Translate fact sheets into foreign languages.
Distribution: Do not rely on the Mailing List. Identify your primary target area (usually the area most impacted or
likely to be impacted by the site), then distribute fact sheets to all residences within that target area, even if you have
to address them as "An important environmental message for the family at..." Use mailing services, door-to-door
canvassing, and leverage local groups (e.g. Environmental Justice or others) for volunteer distribution, etc. Announce
when fact sheets are available. Use press releases, public service announcements, and public TV and radio. State where
fact sheets are available and a contact name, address, and phone number.
Tips
	Hand out fact sheets as people enter meetings or hearings, or place them on chairs before the meeting starts.
	Have extras available and encourage people to take copies to friends.
	Bring the latest fact sheet with you on community visits, and hand it out to residents.
	Ask permission to leave several facts sheets at churches, clubs, libraries, and stores.
	Ask principals to send home a fact sheet with every student.
	Distribute door-to-door with door hangers; never use a mailbox for anything but mail.
RCRA Public Participation Manual - Tools
Fact Sheets/Statements of Basis

-------
RCRA Public Participation Manual - Tools
AEPA
https: //www. e pa. go v/rcra
	Pay to have the fact sheet printed in the local paper; ask them to keep copies in their lobby.
	Offer fact sheets as inserts in neighborhood association newsletters.
	Consider making a Video fact sheet of the progress of site work. Show it at meetings, and broadcast it on local cable
access channels. Place two copies in the Information Repository. Advertise the video and how to get it.
	Contaminant information in fact sheets should contain the chemical name, media contaminated, and contaminant
concentration at the site versus the normal range.
	Consider adding fact sheets to an appropriate community website or social media page.
	Distribute fact sheets to email listservs of impacted communities to notify residents about RCRA permitting or corrective
action activities.
RCRA Public Participation Manual - Tools
Fact Sheets/Statements of Basis

-------